- 28 - Accuracy-Related Penalty Respondent determined that petitioners are liable for the accuracy-related penalty for negligence prescribed by section 6662. Petitioners contend that they should not be liable for the penalty because they acted in reasonable and good faith reliance on the advice of their accountant, Mr. Robert Glen, in preparing their 1990 and 1991 tax returns. They maintain that Mr. Glen was fully aware of all of the facts and circumstances relating to the formation and execution of the plan, as well as petitioner's loans from the plan, and that Mr. Glen failed to advise them to report the amounts received as taxable distributions. Petitioners also maintain that petitioner has no training or special knowledge regarding Federal tax law and qualified plan benefits, and that he did not understand "the application of federal tax laws to the loans he received from the qualified plan."Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
Last modified: May 25, 2011